Farmer v. Brennan

In Farmer v. Brennan, the U.S. Supreme Court addressed the standard for 'deliberate indifference' under the Eighth Amendment in the context of inmate safety. The Court held that prison officials cannot be held liable unless they are subjectively aware of a substantial risk of serious harm and disregard that risk. The judgment of the Court of Appeals was vacated, and the case was remanded for further proceedings consistent with this opinion.

The Court reasoned that the Eighth Amendment prohibits cruel and unusual punishments, and prison officials have a duty to provide humane conditions of confinement, including taking reasonable measures to guarantee inmate safety. However, not every injury suffered by one prisoner at the hands of another translates into constitutional liability. The Court defined "deliberate indifference" as requiring a subjective awareness of a substantial risk of serious harm and a disregard for that risk. The Court rejected an objective test, stating that an official's failure to alleviate a risk they should have perceived but did not, cannot be condemned as the infliction of punishment. The Court also clarified that a prisoner need not show that an official acted or failed to act believing that harm would actually befall an inmate, but rather that the official acted or failed to act despite knowledge of a substantial risk of serious harm. The Court emphasized that a subjective approach does not require a prisoner to await a tragic event before obtaining relief, and that in a suit seeking injunctive relief, the subjective factor should be determined in light of the prison authorities' current attitudes and conduct.